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U. S. NUCLEAR REGULATORY COMMISSION.j .- REGION I',

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Report No. 50-353/89-21,

- Docket No. 50-353-L

License No. CPPR-107 Category B

- Licensee: Philadelphia Electric Company1 2301 Market Street,.

Philadelphia, PA 19101

Facility Name: Limerick Nuclear Generating Station, Unit 2

Inspection At: Limerick, Pennsylvania,

' Inspection Conducted: .ay 30 - ) d , 1989

- Inspectors: SPrd4M 4Y #/'

'JosepWarrasco, Reattor Engineer, DRS, EB date

AcwW _7 /r/s,-

Robert A. McBrearfy, Reactor Eagineer, DRS, EB fiat'e '

Approved by c44 '/ m 7/iYIHi90ack Strosnider, ' Chief, DRS, ENG, MPS date '

; Inspection Summary: Routir.a Unannounced Inspection on May 30 - June 2,.1989(Inspection Report No.. 50-353/89-21)

heasInspected: An inspection was performed of licensee activities relatedto NRC Bulletin 79-14 regarding pipe supports and preservice inspection ofpiping and components. The inspection included review of procedures, program

! implementation and QA/QC activities in the above areas.

Results: No violations or deviations were identified.

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DETAILS

1.0 Persons Contacted

1.1 Philadelphia Electric Company

* D. A. Dipaolo, Superintendent Unit 2 QA* R. L. Payne, Quality Assurance Engineer* D. Shaner, Licensing Tech. Writer* H. R. Wiegle, Superintendent Startup Ops.* D. L. Schmidt, Engineer NED

1.2 Bechtel Power Corporation

D. P. Graham, Plant Design Engineering SupervisorA. Herzog, Engineering SupervisorH. Patel, Pipe Support Engineering Group LeaderW. T. Sullivan, Pipe Support Engineer

* G. C. Kelly, Quality Assurance* W. Ross, PSI Coordinator

1.3 U.S. Nuclear Regulatory Commission

* T. Kenney, Senior Resident Inspector* R. Fuhrmeister, Resident Inspector* M. Evans, Resident Inspector

* Denotes those present during the exit meeting held on June 2, 1989.

2.0 Preservice Inspection Data Review

Limerick Unit 2 preservice inspection data were selected for inspectionto ascertain that the data complied with the licensee's PSI program andthat ASME Section XI and regulatory requirements were met. Data represent-ing the following components were included in the inspection sample:

ASME Class 1 bolting associated with recirculation system pump 2AP201*

Reactor Pressure Vessel Welds (Class 1)

Weld AA, shell 1 to bottom head circumferential weld*

Weld AC, shell 2 to shell S circumferential weld*

Weld AD, shell 3 to shell 4 circumferential weld*

Weld AF, shell 5 to RPV closure flangea

Weld AG, closure head to flange*

Weld BD, shell 2 vertical seam weld*

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Residual Heat Removal System (18" diameter piping - Class 2)

Weld GBB-202-2-FW6,18" x 18" x 18" tee to pipe*

Weld GBB-202-2-FW50, flange to valve PSV-2F055B*

Weld GBB-202-2-28-SW1, 20" x 18" reducer to 20" elbow*

Weld GBB-202-2-28-SW4, 18" pipe to 18" x 18" x 14" reducing tee*

The RPV welds were ultrasonically examined using manual and automatedtechniques, and the closure head flange weld was examined with themagnetic particle method. Volumetric examination of the Class 2 RHRwelds was not required; the code requirement for surface examination was ~

complied with by the use of the magnetic particle examination method.The recirculation pump Class I bolting was examined visually and with theultrasonic examination method.

Examination results were properly documented and indications wereevaluated and dispositioned in compliance with applicable requirements.Supplemental examinations were performed when further information wasrequired to evaluate a reported condition.

2.1 Conclusion

The licensee has complied with code and regulatory requirementsregarding preservice inspection. Examination results are clearlydocumented and the records are readily retrievable.

No violations were identified.

3.0 Licensee Action on Previous Inspection Findings

3.1(0 pen) Unresolved Item 50-353/89-04-01, SNT-TC-1A SpecificExamination for the Certification of Level III Examiners

The item was in regard to the type of questions comprising thespecific examination and whether or not the examination should be a" closed book" examination. At the inspectors' request the licenseeand the General Electric Company submitted questions to the SNT-TC-1AInterpretation Panel to clarify the intent of SNT-TC-1A in thatregard. The Panel's response to those questions arrived at the siteduring the course of this inspection. The Interpretation Panel'sresponse stated that the subject exam should be closed book. Theresponse additionally stated that questions covering specificationsused by the employer should be included, and that specific examina-tions that are formulated in such a manner that every question on theexamination may be answered directly by reviewing the referencematerial provided by the employer's Level III examiner with the

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examination do not meet the SNT-TC-1A recommendation for a closedbook examination. Based on this response, the licensee is consider-ing what action must be taken to assure that the qualification /certification program meets the intent of SNT-TC-1A.

The item will remain open pending completion of the licensee'saction and subsequent NRC review.

3.2 (Closed) Construction Deficiency Report Item 89-00-07 NonconformingTube Steel in Pipe Anchor (SP-HBC-241-E14-Hl)

This item involves incomplete penetration and lack of fusion in alongitudinal seam weld in a structural member for supportSP-HBC-241-E14-H1. This support is located 8'-9" south of columnline J and l'-6" west of column line 30.5.

The inspector observed the repaired tube steel. This repair wasaccomplished by adding a plate 3/8" X 5" X 8 3/16" to the 4".x 9" x "

tube steel to prevent any further separation of the seam weld. Theinspector reviewed the latest drawing, No. SP-HBC-241-E14-H1, andverified that it reflects the repair.

The inspector also reviewed quality control inspection record SH06780which documents the quality assurance inspection of the repair.

Item 89-00-07 is closed.

3.3 (Closed) Unresolved Item 86-20-01 Justification For Allowable Stresses

FSAR table 3.9-21 " Design Loading Combination for Supports for ASMECode Class 1, 2, and 3 Components" gives allowables stresses foremergency and faulted conditions for steel structural members ofnon-standard catalog supports. However, the r,tated values are notderived from the original design codes, ANSI B31.1 and B31.7, sincethese codes do not address increased allowables for emergency andfaulted condition.

The inspector reviewed the licensee's report No. 2N-543 which providesthe justification for using the increased stress allowables. The m

Isupports are designed based on stress performed in accordance withASME Section III, 1971 Edition (condition A/B, C and D). Where theuse of increased allowables for emergency and faulted conditions (Cand D) is allowed. Since ANSI B31.1 or 831.7 codes do not addressallowables for level C and D, ASME Section III, subsection NCequations were used to develop the allowable stress.

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The-inspector determined that the licensee's justification presentedin report No. 2N-543 is adequate and the allowables for faulted andemergency conditions derived in accordance with Subsection NC ofSection III of the ASME Code and presented in the FSAR are moreconservative than the Subsection NF and AISC allowable stresses.Item 86-20-01 is closed.

3.4 (Closed) Bulletin 79-14 Seismic Analysis For As-Built Safety RelatedPiping System

Background - IE Bulletin No. 79-14 was issued on July 2, revised onEly 18; and the first supplement was issued on August 15, 1979. Thebulletin requested licensees to take certain actions to verify thatseismic analyses during the design of the plant actually reflect theas-built condition of the plant. Supplement 2 provided additionalguidance with regard to implementation of the bulletin requirements.

Procedure - The inspector reviewed the specification for the as-builtreconciliation for the Limerick Generating Station, Unit 2, Number8031-P-366-2. The purpose of this specification was to provideprocedures for the as-built reconciliation of: 1) ASME Section IIIand seismic category I piping systems, and 2) Non-ASME seismiccategory II and IIA piping systems.

As-Built P, reconciliation is a physical inspection and evaluation ofthe as-built versus as-analyzed condition of piping and pipe supports

| (P/S) to assure that the analyses are based on an analytic model that.properly reflects the actual configuration of the installation. 1

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The inspector found specification for As-Built Reconciliation (ABR)for Limerick Unit 2 adequate. The above determination was based onthe following:

A well defined purpose and scope including Bechtel Interface*

with GE (on Main Steam lines A thru D and Recirculation Loops Aand B).

Adequate definition of terms and abbreviations used throughout*

the specification.

Clear instructions to process change documents (i.e., FCRs,*

FCNs) into an issued as-built drawing.

Adequate Construction Engineering /QC notification of work| *

completion to Project Engineering via Field As-BuiltReconciliation (FAR) letter.

Adequate instructions for final reconciliation via Engineering*

As-Built Reconciliation (EAR) letter for a given stresscalculation.

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Well defined assignments of responsibilities for*

interdisciplinary interaction.

Implementation - The inspector randomly selected two safety relatedsupports on the RHR system of recirculation loop A and B, and reviewedall the steps of the As-Built Reconciliation (ABR) program. Basedon this review, the inspector had the following findings.

The pipe stress analysis was based on the as-built configuration*

(reviewed for nodal point 229 corresponding to randomlyselected support DCA-204-H2).

The load generated at this nodal point is 1408 lbs.*

The analysis and design of the pipe support was done for a*

corresponding load of 1408 lbs. which is reflected on As-BuiltDrawing DCA-204-H2.

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Results from the pipe stress show that code allowables are*

satisfied.|

The inspector utilized the same engineering approach to check theprocedural and analytical steps for support DCA-204-H7 correspondingto pipe stress nodal point 225 and found acceptable results.

Attachment A is a list of the analysis and design documents thatwere inspected.

Based on the inpection performed, the inspector found nodeficiencies in the licensee's 79-14 program or its implementation.

Bulletin 79-00-14 is closed.

3.5 Management Meetings

Licensee management was informed of the scope and purpose of theinspection at the beginning of the inspection. The findings of theinspection were discussed with the licensee representatives duringthe course of the inspection and presented to the licensee managementat the June 2,1989 exit conference (see paragraph I for attendees).

At no time during the inspection was written material provided tothe licensee by the inspector. The licensee did not indicate thatproprietary information was involved within the scope of thisinspection.

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Attachment A-!

All the documents listed below were prepared by Bechtel for PECO.

1) Specification for As-Built Reconciliation for the Limerick GeneratingStation, Unit'2, Philadelphia Electric Company No. 8031-P-366-2, Revision3, dated December 30, 1988.

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|. 2) Isometric - Reactor building (drywell) Residual Heat Removal, Unit #2,Drawing Number SK-M-2073, Revision L.

3) Pipe stress analysis for Recir. Loop B, Calculation No. 2-10-11, Revision4 (January 23,1989), final as-built per FAR #938-3.

4) Pipe support Reactor Encl. RHR, Unit #2, Drawing No. DCA-204-H2, Revision3.

5) Microfiche 18240000 SPR-86-14 R0 870119 Reactor Recirculation Loop B.

6) Pipe support Design Calculation Hanger No. DCA-204-H2, Revision 3.

7) Isometric - Reactor building (drywell) Residual Heat Removal, Unit #2,Drawing No. SK-M-2072, Revision 4.

8) Piping Stress Analysis Recirculation Loop A Calculation No. 2-10-10,Revision 6 (February 16,1989).

9) Pipe support Reactor Encl. RHR, Unit #2, Drawing No. DCA-204-H7, Revision3.

10) Microfiche 08031000 SRP-86-13, R0 860527, Reactor Recirculation Loop A.

11) Pipe Support Design Calculation Hanger No. DCA-204-H7, Revision 3.

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